White v. Erdos, 1:20-cv-00101

Plaintiff Jermeal White, an SOCF inmate, alleges that on December 30, 2019 unnamed correctional officers sprayed him with O.C. spray, used excessive force (bending hands, throwing him into a window) and caused a shoulder injury requiring stitches and hospital treatment.
White alleges he refused to cuff because he felt unsafe and that officers violated policy by not notifying a supervisor or recording the response before spraying him.
White contends Unit Manager Cynthia Davis was notified repeatedly of threats to his safety (and denied his grievance), and he sued Warden R. Erdos, Davis, and four unnamed John Doe officers under 42 U.S.C. § 1983 seeking declaratory relief and damages.
Plaintiff filed amended complaints (granted by the Court) and was granted in forma pauperis status; the Court conducted the required sua sponte screening under 28 U.S.C. §§ 1915 and 1915A.
The Court found White’s Eighth Amendment claims (failure to protect/excessive force) cognizable against Davis and the unnamed John Doe officers in their individual capacities, but dismissed other claims and defendants.
The Court denied White’s motion for preliminary injunction/TRO for failure to show likelihood of success or irreparable harm and ordered White to provide service forms for Davis and to identify John Doe defendants before service on them.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eighth Amendment excessive force / failure to protect against Davis and John Does	Officers sprayed and used force; Davis knew of threats and was indifferent	Insufficient factual allegations to establish liability for some defendants	Allowed to proceed: Eighth Amendment claims may go forward against Davis and unnamed John Doe officers in their individual capacities
Official-capacity monetary damages	Seeks money from officials in official capacities	State and state officials sued in official capacity are protected by Eleventh Amendment	Dismissed: official-capacity damage claims barred by Eleventh Amendment
Supervisory liability for Warden Erdos	Erdos, as warden, legally responsible and knew of risk	Supervisor liability cannot be based on respondeat superior; must show deliberate indifference/active unconstitutional conduct	Dismissed: Erdos not plausibly alleged to be deliberately indifferent; supervisory claim fails
Grievance / investigation failures	Grievance denials and poor investigation violate rights	No constitutional right to grievance procedures or to investigation	Dismissed: grievance/investigation claims do not state § 1983 claim
Preliminary injunction / TRO	Requests court order to correct ongoing constitutional violations	Plaintiff has not shown likelihood of success or irreparable harm; injunction is extraordinary relief	Denied/Recommended denied: plaintiff failed to meet injunction factors

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must allege factual content permitting plausible inference of liability)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (complaint requires more than labels and conclusions)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for failure-to-protect claims)
Edelman v. Jordan, 415 U.S. 651 (1974) (Eleventh Amendment bars federal damage suits against states absent waiver)
Will v. Michigan Dept. of State Police, 491 U.S. 58 (1989) (official-capacity suits are suits against the state)
Monell v. Dep’t of Social Servs., 436 U.S. 658 (1978) (limits on municipal/supervisory liability under § 1983)
Denton v. Hernandez, 504 U.S. 25 (1992) (standards for dismissing frivolous IFP complaints)
Winter v. Natural Resources Defense Council, 555 U.S. 7 (2008) (standard for preliminary injunctions requires likelihood of success and irreparable harm)